This AskRegs Knowledgebase Q&A was updated on December 21, 2020 to reflect the December 11, 2020 Federal Register which reaffirmed the following flexibilities for standard term programs through the end of the academic year that includes December 31, 2020 or the end of the academic year that includes the end date for the federally-declared qualifying emergency related to COVID-19, whichever occurs later. This extension was already granted under the June 16, 2020 changes to the March 5, 2020 Electronic Announcement.
There are several factors to consider when you decide to extend an existing scheduled break or otherwise reduce the term or academic calendar length due to Coronavirus-related interruptions.
Academic Year Length and Lengths of Standard Terms: First, you must ask yourself, “When we extend our scheduled break or otherwise reduce the length of a term (e.g., starting late), does it shorten the academic year to less than 30 weeks?”
Under 34 CFR 668.3, an academic year in a credit-hour program must consist of 30 weeks of instructional time. If you extend your scheduled break or reduce your term length, it may reduce the number of weeks of instructional time in your term/payment period and thereby your academic year to less than 30 weeks. For example, if you have a program consisting of two 16-week semesters with a 32-week academic year, and the extended break reduces your spring term by two weeks, no further action is necessary. On the other hand, if your academic year consists of two 15-week semesters, and the additional week of scheduled break reduces the 15-week semester to a 14-week semester, you have reduced your academic year length to 29 weeks. If this happens, you must obtain approval from ED. The same is true if you start classes earlier and end earlier than scheduled, or if you start classes later than scheduled.
Per the April 3, 2020 Electronic Announcement, "If an institution determines it will temporarily cease providing instruction, extend a break, or otherwise reduce the length of its term in a manner that results in fewer than 30 weeks of instruction in the academic year as the result of COVID-19 disruptions, it should send an email to [email protected] to request a temporary reduction in the length of its academic year. The request must:
Institutions should include in the subject line of the email the institution’s name, OPEID, and the state where the main campus is located. The request will be reviewed and forwarded to the appropriate School Participation Division, which will communicate its final determination to the institution."
It is NASFAA's understanding based on the March 5, 2020 Electronic Announcement that the U.S. Department of Education (ED) can grant a reduction to as little as 26 weeks for a credit-hour program at this time. To avoid a reduction in your academic year length, you could choose to add days to the end of the term/payment period to make up for the lost week(s) of instructional time.
The June 16, 2020 changes to the March 5th announcement expands on the above guidance, stating: "The Department is aware that, due to ongoing concerns over the COVID-19 emergency, many institutions have found it necessary to adjust their academic calendars. In recognition of this, we are expanding these flexibilities to include all programs, regardless of whether students are returning from travel abroad programs or have been cancelled out of experiential learning opportunities and extending applicable deadlines. All standard terms will be permitted to overlap with an adjacent term without the program being considered non-term. Additionally, a standard semester or trimester may consist of as few as 13 weeks of instructional time and a standard quarter as few as 9 weeks of instructional time without the program being considered a non-standard term program. It should be noted that any reduction in a program’s defined academic year to less than 30 weeks of instructional time must be specifically approved by the School Participation Division (SPD). Submit your request by email to [email protected]. This guidance is applicable through the end of the academic year that includes December 31, 2020 or the end date for the COVID-19 Federally declared emergency, whichever occurs later."
Return of Title IV Funds (R2T4): Based on the March 5, 2020 Electronic Announcement, if you extend an existing scheduled break (such as spring break), the number of days in the scheduled break now includes the previously scheduled break plus the additional days resulting from the extension. These new total days in the extended break are then excluded from both the numerator and the denominator in the R2T4 calculation if the extended break is five or more consecutive days. If you extend the payment period (or period of enrollment) by adding days to the end to make up for a loss of instructional time (or some other reason), you will use the revised payment period begin and end dates in the R2T4 calculation, consistent with guidance under “Reentering the Same Payment Period” in the March 5th Electronic Announcement.
According to guidance NASFAA has received from ED, if the term starts later, the revised number of days are used in the R2T4 calculation. The denominator in an R2T4 calculation must always consist of the number of days the student was scheduled to attend. For students beginning enrollment in say a summer term that will now consist of only eight weeks, the revised number of days in that payment period will comprise the denominator.
The school is not required to redo any R2T4 calculations that were done correctly at the time they were initially performed. See AskRegs Q&A, Must the School Redo R2T4 Calculations That Were Done Before Payment Period Adjustments Were Made Due To Coronavirus?
There are, however, instances when you should re-disburse unearned Title IV aid to students for whom the school already performed the R2T4 calculation or when when disbursing new aid to a student who has withdrawn due to COVID-19. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) schools are still required to perform R2T4 calculations, but schools and students are not required to return any unearned aid resulting from the R2T4 calculation. This is what we are calling the R2T4 waiver. See AskRegs Q&As, How Do We Implement the R2T4 Waiver If We Are Performing the First R2T4 Calculation For the Student? and How Do We Implement the R2T4 Waiver If We Are Re-Disbursing Aid We Already Returned Under the R2T4 Calculation? for details.
Adjusting Loan Periods and Disbursement Dates: According to ED, when you choose to extend a term that begins on or before June 1, 2020, you are not required to change loan period end dates for loan periods that were scheduled to end on the original term end date. See also AskRegs Q&A, Are We Required To Adjust Direct Loan Period End Dates If We Extend Or Shorten Our Terms Due To Coronavirus?
NSLDS Enrollment : Because your institution is closing temporarily by extending spring break, and assuming the institution will reopen within 90 days from the closure and the student will resume attendance when the institution reopens, you do not need to report your students as withdrawn during the temporary closure. See the April 3, 2020 Electronic Announcement for more on reporting in-school status and in-school deferment status.
Paying Federal Work-Study (FWS) Students: You may continue to pay FWS students who were already working an FWS job before the COVID-19 qualifying emergency began and who are unable to continue working due to a COVID-19 related campus closure or moving classes online, provided your institution continues paying its other employees and continues to meet its institutional share requirement. See the April 3, 2020 Electronic Announcement for more on FWS. See also AskRegs Q&A, Can We Continue To Pay FWS Students Who Are Unable To Work FWS Jobs For the 2020-21 Award Year Due To COVID-19?
AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.